(a) An SPFC shall pay to the SAM by April 15 of each year, a tax at the rate of four tenths of one percent on the first $20,000,000 and three tenths of one percent on each dollar after the first $20,000,000, subject to a minimum annual tax of $5,000 and a maximum annual tax of $75,000. Taxes are based upon the direct premiums written or contracted for on policies or contracts of insurance, other than reinsurance policies or contracts written by the SPFC, during the year ending December 31 next preceding, after deducting from the direct premiums subject to the tax the amounts paid to insureds as returned premiums which must include dividends on unabsorbed premiums or premium deposits returned or credited to insureds.
(b) An SPFC shall pay to the SAM by April 15 of each year, a tax at the rate of two hundred and twenty five thousandths of one percent on the first $20,000,000 of assumed reinsurance premium, and one hundred fifty thousandths of one percent on the next $20,000,000, and fifty thousandths of one percent on the next, $20,000,000 and twenty five thousandths of one percent of each dollar after that, subject to a minimum annual tax of $5,000 and a maximum annual tax of $75,000. However, no reinsurance tax applies to premiums for risks or portions of risks which are subject to taxation on a direct basis, pursuant to subsection (a). A premium tax is not payable in connection with the receipt of assets in exchange for the assumption of loss reserves and other liabilities of another insurer under common ownership and control if the transaction is part of a plan to discontinue the operations of the other insurer and if the intent of the parties to the transaction is to renew or maintain business with the SPFC.
(c) Each protected cell of the SPFC must be taxed as if it is a separate and distinct SPFC.
(d) In addition to the taxes provided under (a) and (b) of this section, each SPFC must be granted a reduction in the income tax liability shown on its income tax return for each taxable year by 90% for such income that meets the requirements of sections 934 and 937(b) of the Internal Revenue Code of 1986, as amended, and any successor provisions to that Code, and the Treasury Regulations promulgated thereunder, as being from Territory sources or effectively connected with the conduct of a trade or business within the Territory.
(e)
(1) Every person who receives a payment or allocation subject to the tax imposed by Sections 704, 871(a)(1), 881, 884, or 1446 of the Internal Revenue Code as applicable in the Territory from an SPFC is exempt from the payment of 100 percent of such tax.
(2) An SPFC is exempt from the requirement to withhold tax pursuant to sections 1441, 1442, and 1446 of the Internal Revenue Code as applicable in the Territory to the extent that such payments are exempt from the tax described in paragraph (1).
(f) An SPFC is exempt from any other taxes imposed by the Territory, including real property used in the business of the SPFC, gross receipts taxes, and excise taxes.